TaxTMI 
TaxTMI 
2022 (4) TMI 548
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.... The impugned order of the learned Commissioner of Income-tax (Appeals) passed under Section 250 of the Income Tax Act, 1961 is opposed to law, weight of evidence, probabilities, facts and circumstances of the Appellant's case. 2. The learned Commissioner of Income-tax (Appeals) erred in holding that there was no response from the appellant in respect of the hearing fixed on 09.09.2021 when the appellant has filed a letter seeking adjournment of 14 days to file the documents and consequently the order passed is in violation of the principles of natural justice on the facts and circumstances of the case. 3. The learned Commissioner of Income-tax (Appeals) failed to appreciate that the notice issued under section 154/155....
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....led to appreciate that the learned Assessing Officer erred in holding that the appellant furnished the cheque in favour of CIT (Central), Hyderabad when the appellant has produced the demand draft as evidence of payment and the assessment order passed by the learned Assessing Officer at Hyderabad in respect of payment of Rs. 3,00,000/- on the facts and circumstances of the case. 8. The learned Commissioner of Income-tax (Appeals) failed to appreciate that the appellant claimed said amount of Rs. 3,00,000/- as advance tax paid in the return of income filed on 28.10.2009 itself before the learned Assessing Officer, Hyderabad and the learned Commissioner of Income-tax (Appeals) erred in holding that the appellant has not produced anyt....
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....ng the notice under section 154 of the _Act vide dated 27.09.2017 in respect of/ rectification of the credit given in the assessment order passed on 21.12.2010 and the same is barred by time as per provisions of section 154(7) of the Income-tax Act, 1961 and consequently the order passed under section 154 of the Act is not sustainable in law on the facts and circumstances of the case. 2. The appellant craves leave of this Hon'ble Tribunal, to add, alter, delete, amend or substitute any or all of the above grounds of appeal as may be necessary at the time of hearing. 3. For these and other grounds that may be urged at the time of hearing of appeal, the appellant prays that the appeal may be allowed for the advancement o....
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....any such request was made when the amount was deposited in PD account. As regards self-assessment tax of Rs. 3,00,000/- the argument of the appellant is that he had paid self-assessment tax of Rs. 5,00,000/- on 29.09.2009. The appellant has also argued that the tax credit for advance tax (Rs. 2,00,000/- ) and self-assessment tax (Rs. 3,00,000/-) was given by the AO at Hyderabad and the AO at Bangalore could not have rectified the order as it was not his mistake, if any, but that of the AO at Hyderabad. As such the appellant has argued that the AO at Bangalore was lacking jurisdiction to issue a notice under Section 154 of the Act. 6. The CIT(Appeals) observed that as regards the jurisdiction of the AO at Bangalore to issue notice under S....